The Secretary of State for Work and Pensions did not owe a common law duty of care in discharging his functions under the Child Support Act 1991.

The Court of Appeal so stated when dismissing the appeal of Charlotte Rowley, Laura Rowley, Alexander Rowley, by his litigation friend and sister Laura Rowley, and their mother, Denise Rowley, against the decision of Judge Grenfell, QC, in the